K A SUJIT CHANDAN,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE BENGALURU.-5(2)(1), BENGALURU

In the result all the three appeals in ITA Nos

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

capital gains ITA Nos.962 & 963/Bang/2025 K.S. Akhilesh Babu ITA No.964/Bang/2025 K.A. Sujith Chandan ITA No.965/Bang/2025 K.G. Subbarama Setty Page 11 of 33 of Rs.17,96,704/- (Rs.4,92,69,179 – 4,74,72,475) was added back to the income of the assessee and brought to tax. 3.6 With regard to the Notional rent on residential property owned

M/S PARAMANAND AND SONS,BENGALURU vs. INCOME TAX OFFICER, WARD 5(2)(1), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Years : 2020-21

Capital gains' is a loss and the assessee has income assessable under any other head of income, the assessee shall not be entitled to have such loss set off against income under the other head. 5. The provisions of section 72

PRAKASH BARE,BENGALURU vs. DCIT CIRCLE 2(2)(1), KORAMANGALA, BENGALURU

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kassessment Year :2020-21

72,50,000/- and computation of capital gain from the ITR is reproduced by the AO. From the observation of the details of the capital gain computation sheet, a notice under section

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), BANGALORE vs. M/S OLIVIYA APPARELS PRIVATE LIMITED, BANGALORE

In the result, all the appeals filed by the revenue and the assessee are dismissed

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S

capital gains. Bad debts written off ITA Nos.1211 to 1212 & 1251 to 1253/Bang/2013 Page 6 of 23 14. On perusal of the return filed in response to notice u/s. 153C, the AO noticed that the assessee has claimed a sum of Rs.30,34,124 as bad debts written off. The AO disallowed the said claim for the reason that

M/S. OLIVIA APPARELS PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), BANGALORE

In the result, all the appeals filed by the revenue and the assessee are dismissed

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S

capital gains. Bad debts written off ITA Nos.1211 to 1212 & 1251 to 1253/Bang/2013 Page 6 of 23 14. On perusal of the return filed in response to notice u/s. 153C, the AO noticed that the assessee has claimed a sum of Rs.30,34,124 as bad debts written off. The AO disallowed the said claim for the reason that

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), BANGALORE vs. M/S OLIVIYA APPARELS PRIVATE LIMITED, BANGALORE

In the result, all the appeals filed by the revenue and the assessee are dismissed

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S

capital gains. Bad debts written off ITA Nos.1211 to 1212 & 1251 to 1253/Bang/2013 Page 6 of 23 14. On perusal of the return filed in response to notice u/s. 153C, the AO noticed that the assessee has claimed a sum of Rs.30,34,124 as bad debts written off. The AO disallowed the said claim for the reason that

M/S OLIVIA APPARELS PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), BANGALORE

In the result, all the appeals filed by the revenue and the assessee are dismissed

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S

capital gains. Bad debts written off ITA Nos.1211 to 1212 & 1251 to 1253/Bang/2013 Page 6 of 23 14. On perusal of the return filed in response to notice u/s. 153C, the AO noticed that the assessee has claimed a sum of Rs.30,34,124 as bad debts written off. The AO disallowed the said claim for the reason that

M/S OLIVIA APPARELS PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), BANGALORE

In the result, all the appeals filed by the revenue and the assessee are dismissed

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S

capital gains. Bad debts written off ITA Nos.1211 to 1212 & 1251 to 1253/Bang/2013 Page 6 of 23 14. On perusal of the return filed in response to notice u/s. 153C, the AO noticed that the assessee has claimed a sum of Rs.30,34,124 as bad debts written off. The AO disallowed the said claim for the reason that

DCIT, CC-2(1), BENGALURU, BENGALURU vs. CHAITANYA PROPERTIES PVT LTD, BENGALURU

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2011-12

section 14A of the Act to the file of the learned CIT(A) for reconsideration. 10. The learned CIT(A), vide order dated 30-03-2024, once again decided the issue of capital gains and business income from the JDA in favor of the assessee, following the Tribunal's decision in the assessee's own case

CHANDRASHEKAR HEMANTH ,BENGALURU vs. INCOME TAX OFFICER WARD 7(2)(4) BANGALORE, BENGALURU

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2017-18

Capital gains" and claims that the loss or any part thereof should be carried forward under sub-section (1) of section 72

TATA ELXSI LIMITED ,BANGALORE vs. DEPUTY COMMISIONER INCOMER TAX, CIRCLE-7(1)(1), BANGALORE

Accordingly, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahuassessment Year : 2018-19 M/S. Tata Elxsi Ltd., The Deputy 126, Itpb Road, Commissioner Hoody, Of Income Tax, Whitefield, Circle – 7(1)(1), Bangalore – 560 048. Bangalore. Vs. Pan: Aaact7872Q Appellant Respondent

capital gains and income from other sources. Insofar as income under the head 'profits and gains of business or professions' is concerned, provisions thereto are contained in Sections 28 to 44DB of the Act. Section 28 specifies various incomes which shall be chargeable to income tax under this head. Thereafter, Section 29 provides that income referred to in Section

M/S. TATA ELXSI LIMITED., ,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, CIRCLE-7(1)(1), BANGALORE

In the result, all the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri George George K. & Shri Chandra Poojari

capital gains and income from other sources. Insofar as income under the head 'profits and gains of business or professions' is concerned, provisions thereto are contained in Sections 28 to 44DB of the Act. Section 28 specifies various incomes which shall be chargeable to income tax under this head. Thereafter, Section 29 provides that income referred to in Section

RANGARAJ ROHINI,INDIRANAGAR BANGALORE vs. DEPUTY COMMSSIONER OF INCOME TAX ASMNT CIRCLE 2(1) BANGALORE, KORMANGALA BANGALORE

In the result, the appeal filed by the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Prakash Chand Yadav

gains. The section allows deduction of the “cost of acquisition” actually incurred by the assessee from the full value of consideration received or accruing as a result of the transfer of a capital asset. 12.2 In the present case, the assessee has claimed the cost of acquisition at ₹77,14,720/-, comprising ₹72

SHRI. VADAGUR NARAYANAPPA PREMACHANDRA,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-2(1), BANGALORE

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

72,725/-. The assessee at the time of assessment, had submitted that as per the settlement deed, the family members had handed Page 3 of 10 IT(IT)A No. 1032/Bang/2023 over the developer a total extent of land of 1,35,461 Sq.ft. including 13,120 Sq.ft. which belonged to the other parties. The assessee further submitted that

IBM GLOBAL SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-11(1), BANGALORE

In the result, the appeal filed by the assessee stands allowed

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2000-2001

72 or sub-section (1) or sub section (3) him, the provisions of this section shall not of section 74 in so far as such loss relates to apply to him for any of the relevant the business of the undertaking, shall be assessment years. carried forward or set off where such loss [(8) References in sub-section

M/S UB SPORTS MANAGEMENT OVERSEAS LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX(INTERNATIONAL TAXATION) CIRCLE-1(2), BANGALORE

In the result, the appeals filed by the assessees are partly allowed

Bench: Shri George George K. & Ms. Padmavathy S.

capital gains (based on the assessed income) of Rs. 96,52,74,468/-. We shall adjudicate the above two issues as under: - Re-computation of arm's length price of shares sold by the assessee amounting to Rs. 262,27,80,021/- (Ground Nos. 1 to 14): 6. The brief facts in relation to the above issue are that

M/S PALMER INVESTMENT GROUP LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-2(1), BANGALORE

In the result, the appeals filed by the assessees are partly allowed

Bench: Shri George George K. & Ms. Padmavathy S.

capital gains (based on the assessed income) of Rs. 96,52,74,468/-. We shall adjudicate the above two issues as under: - Re-computation of arm's length price of shares sold by the assessee amounting to Rs. 262,27,80,021/- (Ground Nos. 1 to 14): 6. The brief facts in relation to the above issue are that

CANARA BANK,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE, BENGALURU

Bench: SHRI WASEEM AHMED, ACCOUNTANT MEMBER\nAND\nSHRI KESHAV DUBEY, JUDICIAL MEMBER\nITA No.210/Bang/2024\nAssessment Year: 2017-18\nM/s Canara Bank\nFM wing, Head Office,\n112, J.C. Road\nBangalore 560002\nVs.\nDCIT\nCircle-2(1)(1)\nBangalore\nPAN NO : AAACC6106G\nAPPELLANT\nRESPONDENT\nITA No.222/Bang/2024\nAssessment Year: 2017-18\nDCIT\nCircle-2(1)(1)\nBangalore\nVs.\nM/s Canara Bank\nFM wing, Head Office,\n112, J.C. Road\nBangalore 560 002\nAPPELLANT\nRESPONDENT\nITA No.1154/Bang/2023\nAsses

Capital Gain on Sale of shares of CanFin\nHome Ltd.\n9.\nDisallowance of Provision for Bad & Doubtful Debt u/s\n36(1)(viia) (viiu)\n10.\nShort Allowance of Tax Deducted at Source\n11.\nShort Allowance of Tax Paid by Overseas Branch u/s\n90/91\n12.\nApplicability of Provisions of MAT u/s 115JB\nTOTAL\n1,02,865\n703,92,01,889\n1569

WIPRO LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

section 14A as computed under Rule 8D(2)(iii) cannot be more than the actual expenditure which can be relatable for earning the exempt income and debited to the Profit and Loss account. In the case on hand the disallowance made by the assessee on its own is not the total expenditure debited to the profit and loss account